Sect, i—GENERALLY 141

been held removable, e.g., fire engines and steam
engines (v), vats and coppers for soap boiling (w), cider
mills (x), erections of wood on brick foundations (y),
saltpans (z), glasshouses of nurserymen (a).

Fixtures for Ornament and Convenience.—This is
a more limited exception than the last, and seems to have
been allowed to creep in to counteract the great incon-
venience to tenants that arose by reason of every slight
attachment, even of their household furniture, to the
structure of the house, resulting in the loss of their property.

Articles attached not merely for temporary purposes,
but as a permanent improvement, cannot be removed,
and there is a similar restriction to that in respect of
trade fixtures, that the removal must be made without
serious damage to the freehold (b).

A great variety of articles have been held removable
under this heading, e.g., hangings and tapestry (c), stoves
and grates (d), carpets (e), furnaces and coppers (/),
bookcases screwed to walls (g).

The tenant's right to sever trade and ornamental
fixtures is effective only if the article can be removed (A),
and it is in fact removed, during the existence of the
term (i). This latter rule applies even where there is a
forfeiture (/) or a surrender by the tenant with a view to

(v) Ward v. Dudley (1887), 57 L.T. 20 ; 34 Digest 613, 775.
(w) Poole's Case (1703), 1 Salk. 368 ; 31 Digest 193, 3294.
(x) Lawton v. Lawton (1743), 3 Atk. 13 ; 31 Digest 195, 3313.
(y) Penton v. Robart (1801), 2 East, 88 ; 31 Digest 194, 3298.
(z) Mansfield v.Blackburne (1840), 6 Bing. N.C. 426; 31 Digest 2QQ.3490.

(a) Mears v. Callender, [1901] 2 Ch. 388 ; 31 Digest 209, 3488.

(b) See cases cited in note (u), supra.

(c) Squier v. Mayer (1701), Freem. Ch. 249 ; 38 Digest 663, 67.

(d) Lee v. Risdon (supra).

(e) Hellawell v. Eastwood (1851), 6 Ex. 295 ; 31 Digest 187, 3277.
(/) Squier v. Mayer (supra).

(g) Birch v. Dawson (1834), 2 Ad. & El. 37 ; 44 Digest 714, 5615.

(h) A very v. Cheslyn (supra) ; Pole-Carew v. Western Counties <&
General Manure Co. (supra).

(i) Poole's Case (supra) ; Dudley v. Warde (supra) ; Elwes v. Maw
(supra) ; Lyde v. Russell (1830), 1 B. & Ad. 394 ; 31 Digest 198, 3370 ;
Gibson v. Hammersmith & City Railway Co. (supra),

(;) Pugh v. Avion (1869), L.R. 3 Eq. 626 ; 31 Digest 201, 3420.